Case Digest (G.R. No. 140128)
Case Digest (G.R. No. 140128)
Facts:
Arnold P. Mollaneda v. Leonida C. Umacob, G.R. No. 140128, June 06, 2001, Supreme Court Third Division, Sandoval-Gutierrez, J., writing for the Court.
In September 1994, Leonida Umacob (respondent), a public school teacher, filed an affidavit-complaint with the Civil Service Commission — Regional Office XI (CSC-RO XI) accusing Arnold Mollaneda (petitioner), then Schools Division Superintendent, of hugging, kissing and allegedly groping her breast inside an office on September 7, 1994. Respondent furnished a copy of her affidavit to the Department of Education, Culture and Sports — Regional Office XI (DECS-RO XI), which caused Regional Director Susana Cabahug to direct formation of a committee to investigate the complaint on September 30, 1994.
Petitioner answered the CSC complaint in October 1994, denying the allegations and asserting material contradictions in respondent’s versions, presenting affidavits from his witnesses who said no sexual harassment occurred and that the interview was observable through a glass panel. The DECS investigating committee recommended “the dropping of the case” for lack of merit, but the CSC-RO XI issued a resolution on June 5, 1995 finding a prima facie case and forwarded the records to the Civil Service Commission (Commission).
The Commission designated Atty. Anacleto Buena as hearing officer to receive evidence; a formal administrative hearing followed. On July 7, 1997 the Commission, in Resolution No. 973277, found petitioner guilty of grave misconduct and conduct grossly prejudicial to the best interest of the service and meted the penalty of dismissal. A motion for reconsideration was denied in Resolution No. 981761.
Petitioner appealed to the Court of Appeals (CA) in CA-G.R. SP No. 48902, raising primarily denial of due process (because the Commissioners did not personally witness testimonies), the purported DECS dismissal/recommendation, and the alleged hearsay character of respondent’s corroborative witnesses. On May 14, 1999 the CA affirmed the Commission’s decision in toto, holding that administrative factfinding — including assessment of witness credibility — is entitled to great weight and that the Commission properly exercised its powers; the CA also treated the DECS resolution as merely recommendatory and sustained the admissibility of testimony showing that respondent had related the incident to others. The CA denied petitioner’s motion for reconsideration on August 26, 1999.
Petitioner then filed a petition for review on certiorari under Rule 45 to the Supreme Court, challenging the CA’s deference to the Commission, asserting due process violations from delegation to a hearing officer, contesting the treatment of certain testimony as non-hearsay, and invoking the DECS recommendatory resolution and his subsequent acquittal in the criminal prosecution (Municipal Trial Court, Branch 5, Davao City) as exculpatory. The Supreme Court resolved the petition in this decision.
Issues:
- Did the Commission’s delegation of the taking of testimony to a hearing officer and the Commissioners’ not personally observing witness demeanor deny petitioner due process?
- Was the testimony of respondent’s witnesses (that respondent related the incident to them) inadmissible hearsay?
- Does the DECS recommending resolution to “drop the case” or the dismissal of the related criminal prosecution bar administrative discipline or require petitioner’s exoneration?
- Was the Court of Appeals’ deference to the Commission’s factual findings proper?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)